Public Policy

Public Policy Engagement & Disclosure of Political Activities

Allergan believes that informed public policy plays a critical role in its ability to achieve its goal of pursuing medical advances to help patients live life to its fullest potential. Therefore, Allergan, Inc. and Allergan USA, Inc. (collectively referred to herein as “Allergan”1) engage in various efforts to advance public policies that support healthcare innovation and improve patient access to needed medical treatments, while also advocating for a fair, free market system that will provide the best environment for continued innovation.

These efforts by Allergan include direct and indirect engagement with and advocacy before federal, state and local government officials, sponsoring a federal political action committee, contributing to state and local candidates and committees where permitted and supporting and participating in industry and trade organizations. We believe that such public policy engagement is an important and appropriate role for companies in open societies when conducted in a legal and transparent manner.

Our Policy Positions & Approach

Allergan’s public policy priorities and positions are determined in consultation with the company’s business operations and are approved by our senior management. We engage in public policy debates primarily by communicating information to government officials and policy makers. In the U.S., our Government Affairs team is responsible for advocacy activities with the U.S. Congress and state governors and legislatures, as well as with other federal, state and local government bodies and agencies. Our Grassroots Action Network also educates our U.S.-based employees on important legislative issues and serves as a conduit through which they can communicate with their elected representatives. Outside the U.S., advocacy activities are managed at the country, regional or local level, with support from regional and corporate executive leadership.

Lobbying

In the U.S., a range of lobbying registration and disclosure laws exist with which Allergan complies. At the federal level, we comply with the Lobbying Disclosure Act, which requires us to file quarterly reports with the U.S. Congress to disclose the issues we are lobbying and the amount we spend doing so. These reports call for the disclosure of the expenses associated with lobbying the federal government, including those incurred by our Government Affairs team and non-lobbyist employees, amounts paid to outside lobbying firms and consultants and the portion of our trade association dues attributable to those associations’ federal lobbying. For calendar year 2018, Allergan reported total U.S. federal lobbying expenditures of $3,090,000 and $1,540,000 on state lobbying.

In the U.S. in 2019, the top issues that our company has lobbied at the federal level include:

Allergan’s Social Contract with Patients, including patient access to and affordability of prescription medicines.

Additionally, in each state where Allergan engages in lobbying, we comply with that state’s specific lobbying registration, disclosure and other compliance requirements. For 2019, our state lobbying efforts have predominantly been focused on nine states: California, Florida, Illinois, Massachusetts, New Jersey, New York, Ohio, Pennsylvania and Texas.

In the U.S. in 2019, the top issues that our company has lobbied at the state level include:

Allergan’s Social Contract with Patients, including patient access to and affordability of prescription medicines.

Industry & Trade Association Memberships

Allergan is a member of industry and trade groups that represent both the pharmaceutical industry and the business community at large so that we may participate in bringing about consensus on broad policy issues that can impact our business objectives and ability to serve patients. Allergan's membership in these industry and trade groups comes with the understanding that, although we may not always agree with the positions of the larger organizations and/or other members, we are committed to participating in the discussions and voicing our concerns as appropriate through our colleagues who serve on the boards and committees of these groups. We may even recuse ourselves from related association or industry group activities if our participation would not advance Allergan’s interests.

Political Contributions

While U.S. federal law prohibits corporations from making political contributions to federal candidates, companies can establish political action committees that are funded solely through voluntary employee contributions. The Allergan, Inc. Political Action Committee (“Allergan, Inc. PAC”) provides eligible employees a direct means to voluntarily participate in the political process that can affect public policy issues of importance to Allergan’s business interests.

The Allergan, Inc. PAC operates in accordance with all relevant federal and state laws and contributes to candidates from both parties. When selecting candidates to support, priority is given to candidates who understand business issues of importance to Allergan, as well as to candidates who represent states or districts where the company has facilities or employees. Contributions are always made in the best interest of the company and are never made in recognition of the private political preferences of company executives. Input from Allergan employees who participate in the PAC is considered when selecting candidates to support, but all contribution recommendations must be approved by the PAC Treasurer. All Allergan, Inc. PAC contributions are publicly disclosed via reports which are available on the Federal Election Commission’s website at www.fec.gov..

In certain jurisdictions where doing so is permitted, Allergan makes corporate contributions to support election campaigns, political action committees, party committees and ballot measure committees. Allergan supports state candidates from both parties and applies the same criteria as with the Allergan, Inc. PAC in selecting which recipients to support.

On a semi-annual basis, Allergan makes a list of all corporate state and local political contributions made to support candidates, committees, political parties and ballot measure committees available via this website. Beginning with 2015, this information will be archived and available on this website for up to five years.

While Allergan has not supported any “super-PACs” or made independent expenditures on behalf of any candidate, should it do so, it will make a disclosure on this website.

Compliance

Allergan believes that its efforts to influence public policy and its participation in the political process are critical to advancing the company’s interests. We are also firmly committed to doing so only in a legal and transparent manner and have in place various measures that support this commitment.

Allergan, Inc.’s and Allergan USA, Inc.’s Boards of Directors oversee each respective company’s participation in the political process and the measures taken to ensure compliance with the various laws regulating such participation. Our Executive Vice President and Chief Communications Officer submits a semi-annual report on corporate political contributions to the Board of our parent company for its review. In addition, our contributions, policies and practices are reviewed and overseen by the Audit and Compliance Committee. For these reports, which also describe any changes in our policies, we invite comments and questions.

All our employees must abide by Allergan’s global corporate Code of Conduct (available on this website). This Code defines the way we conduct our affairs with each other, with our stakeholders and with external parties. The Code applies to our interactions with government officials, including our advocacy activities on public policy issues, and is intended to ensure that all information we provide to government officials and entities is complete and accurate to the best of an employee’s knowledge and belief.

Our Code of Conduct specifically prohibits employees from using corporate funds or other resources for political purposes without prior approval by the Company’s Government Affairs Department (Vice President, Government Affairs; Associate Vice President, State Government Affairs); Legal Department (General Counsel, Deputy General Counsel); or Compliance Department (Chief Compliance Officer).

Our corporate policy on ethical business practices includes guidelines conforming to the U.S. anti-kickback laws and Foreign Corrupt Practices Act, making clear that no illegal payments of any kind (monetary or otherwise) are to be offered or made to individuals or entities—including local, state or federal government or political party officials or candidates in the U.S.; government or political party officials or candidates of any other nation; or officials of public international organizations—at any time or under any circumstances.

To ensure compliance with these policies and federal and state laws, outside legal experts provide periodic guidance to our company on required disclosure of its political activities. We also perform periodic audits to assess and enforce compliance with our policy governing our corporate and PAC contributions.

Questions regarding Allergan’s public policy activities or political contributions, or how to become more involved in the policies that affect Allergan, should be directed to Allergan’s Government Affairs Department. Questions regarding the Allergan, Inc. PAC should be directed to: Treasurer, Allergan, Inc. PAC, 500 North Capitol Street, NW, Suite 330, Washington, DC 20001.

[1] U.S. federal law prohibits Allergan plc from participating in U.S. election-related matters because it is not incorporated in the United States; however, certain of Allergan plc’s U.S. subsidiaries – Allergan, Inc. and Allergan USA, Inc. – use their own U.S.-derived resources to independently participate in the political process.

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